Thinking Beyond Compliance Medical Device Whitepaper

This white paper is based on a research study with leading medical device companies - from startups to multibillion dollar enterprises - to explore how they are balancing new product development with compliance requirements.

Transcript of "Thinking Beyond Compliance Medical Device Whitepaper"

2.
Executive Summary
Increased regulatory scrutiny is a reality in today’s medical device industry.
Over the last several years many of the industry’s leading companies
have been hit with an injunction, undergone a product recall, or found
themselves operating under FDA consent decree. At the same time, the
pressure for growth on these companies has never been greater. Driven by
Wall Street, the pace of new technology, emerging market opportunities,
and competition from well funded start-ups, medical device executives find
themselves in an environment where they must continually innovate with
flawless execution to survive.
Given this challenging environment, medical device companies are working
hard to design and implement effective, high functioning innovation engines
while simultaneously ensuring full FDA compliance. Finding the right balance
between what can seem like competing objectives – and understanding how
leading companies are doing so - is the focus of this paper.
Kalypso examined the innovation and new product development processes
of more than 20 leading medical device companies.
Kalypso research and analysis found:
• Designing and maintaining an effective, high-functioning innovation
engine while at the same time ensuring full FDA compliance is
of paramount concern to today’s medical device executive.
• All companies examined have a defined new product development
process structure in place and have implemented some form of
Phase Gate or Toll Gate process, embraced the concept of cross-
functional teams, and established some form of senior decision
making committee to make project go/no-go decisions. Yet,
despite having these product development fundamentals in
place, over half of the companies examined are not meeting
product development effectiveness goals as measured by
their own return on R&D investment, new product revenue
contribution, time to market, or schedule predictability metrics.
Of those, an alarming number report falling far short.
• A well-designed innovation and product development process
based on common industry practices is not enough. Leading
companies are learning from past failures and are implementing
next generation techniques and tools to make step function
improvements in development effectiveness while complying
with increasingly stringent regulatory requirements.
Beyond Compliance: Medical Device Product Development 2

3.
• Next generation process improvements fall into one of four
categories: (1) Process Definition and Work Flow Structure, (2)
Innovation Governance and Decision Making, (3) Project Teams
and Team Structure, and (4) Software Systems and Tools. The
best performing companies have a clear understanding of these
elements and have made significant improvements in each.
Process Definition and Work Flow Structure:
A Roadmap for Project Execution
A major challenge in achieving improved product development performance
is determining ways in which design control processes can be applied
without becoming overly bureaucratic. The top performing medical device
companies demonstrate a clear understanding of the intent behind design
controls and have structured their development process accordingly.
When it comes to product development process structure, medical device
firms generally take one of two approaches: (1) a single process structure
encompassing both business and design control work flows, or (2) two
separate but aligned systems.
Single Process Structure: Business Process and
Design Control as One in the Same
With a single process structure, all elements of the product development
process are captured within design control procedures using a set of
detailed standard operating procedures (SOPs) and work instructions
to describe the who, what, and how for each task, whether the task is
governed by FDA regulations or not. For example, business-oriented
processes such as market assessment, intellectual property assessment,
or project financial justification, are spelled out within the same set of
work instructions as the Design and Development Plan or Requirements
Traceability Matrix.
This approach has the advantage of keeping all development procedures in
one place with one system designed to address both business and quality
system needs. However, research participants were quick to point out that
this approach combines rigidly-controlled design control requirements with
more business-oriented processes that the FDA is not concerned about,
and therefore can unnecessarily bog down project teams that require more
flexibility to adapt business processes to specific project needs. After all, the
FDA is concerned about product safety and efficacy, not whether a product
makes money or fits the company strategy.
3 Beyond Compliance: Medical Device Product Development

4.
By intermingling business-oriented processes with design control
procedures, companies inadvertently increase the opportunities for non-
compliance. Once a company starts down this all-in-one path, process
bureaucracy can grow as layer upon layer of procedure detail is added to
cover each work flow scenario or corner case, regardless of whether or not
the tasks are governed by design controls. With more detail, project teams
are left with less, not more, flexibility to manage a project’s business needs.
Nowhere was this phenomenon more evident than in those companies who
have experienced a recent FDA warning letter or consent decree. These
companies tend to err on the side of more prescriptive procedures, not less.
The process pendulum swings to the far end of the bureaucracy spectrum
and, as a result, delivery performance suffers.
Figure 1 uses a two-by-two matrix to contrast varying levels of compliance
burden (i.e., compliance process bureaucracy) against a spectrum of new
product development process maturity. Kalypso found that medical device
companies typically fall into one of the four resulting quadrants, with the
highest performing companies falling in the upper right hand quadrant.
The High Performers have achieved:
• Well defined development processes ingrained in company culture
• Project selection governed by a well functioning portfolio
management process that is linked to innovation strategy
• High functioning core teams accountable for project execution
• Platform strategies that encourage design re-use
• A well defined technology development and open
innovation process linked to product roadmaps
• Accountability for process performance metrics
that track annual improvement
• A well functioning quality management system that has not
become unwieldy with unnecessary layers of process bureaucracy
Companies who found themselves in one of the other three quadrants
were not getting the business results they desire. The goal is to move your
company to the upper right quadrant without jeopardizing regulatory
compliance, ultimately achieving a mature product development process
coupled with low compliance burden.
Beyond Compliance: Medical Device Product Development 4

5.
High Well-intentioned High Performers
• Consistent, repeatable • Strong Business Results
delivery performance
New Product Development
• Time-to-market lags
• Unnecessary audit
Process Maturity
exposure
Compliance-driven Developing
• Poor business results • Inconsistent delivery
performance
• Slow time-to-market
Low
High Low
Compliance Burden (i.e. Bureaucracy)
Figure 1: NPD Maturity / Compliance Framework
The goal is to move your company to the upper right
quadrant without jeopardizing regulatory compliance
Separate But Aligned Systems Allow
Flexibility Where Appropriate
Top performing companies have established two separate, but aligned
systems as an alternative to the single process structure. Business-oriented
processes that require room for judgment and flexibility are set up as a
supplement to rigorously-controlled design control procedures. While an
important part of the overall delivery process, deliverables such as business
plans, go-to-market strategies, sales plans, and support plans do not go
through the same level of process adherence scrutiny as design control
deliverables such as the Design and Development Plan, Requirements
Traceability Matrix, Risk Management Plan, Design Validation Report, or
Manufacturing Transfer Plan. However, linkages between the two distinct
processes are highlighted to draw attention to interdependencies or key
connection points (see Figure 2).
Sue Pierce, Senior Director, Product Development Process for Ventana
Medical Systems, a cancer screening equipment company, explained the
benefits of this approach. “By separating business-oriented processes from
rigidly-controlled design control procedures, we have, in effect, given our
project teams more flexibility to adapt work flow to specific project needs.
Project teams no longer feel like they have to follow process for process
sake. Instead, they are able to adapt business process guidelines using
experience and judgment without jeopardizing design control compliance.”
5 Beyond Compliance: Medical Device Product Development

6.
Business Process Quality Management System
0 1 2 3 4
Workflow 1 Workflow 1 Workflow 1
Quali
Manu ty
Workflow 1 Workflow 2
y
al Polic
Workflow 2 Workflow 3 Workflow 2 Workflow 1
Inte ,
Workflow 4 Workflow 5 depa r/Intra- Who t,
rtme Wha n
SOPs nt Whe
Workflow 3 Workflow 3
Workflow 6 Work
Prod Instruct
uct ions
Workflow 7 Docu Specifica & How
ment ti
Workflow 8 ation on
Reco lts
rds Resu
Figure 2: Product Development &
Quality Management System Linkage
The new product development process provides work flow guidance to project
teams for effective development execution. It references the Quality Management System
where necessary for more prescriptive design control procedures and work instruction.
Companies that have adopted this approach have discovered additional
opportunities to streamline by decreasing the total number of development
deliverables and reducing the number of deliverables that need to be
circulated for sign off. One leading medical device company went so far as
to not require any signatures on their business deliverables, as going back
to each executive to collect a signature provided no added value and only
delayed the process. Instead, Governance Committee approval at each
phase gate ensures that the deliverables are complete and provide the
information necessary to make the phase gate go/no-go business decision.
Another leading company, with a mature, high performing phase gate
process, decided to document their business and design control procedures
under one quality system, but established two distinct deliverable
categories. Prescriptive templates without room for interpretation are
in place for deliverables that fall under design controls. All other process
documentation, including business-oriented deliverables, uses simplified
outlines that leave room for the judgment of experienced project team
leaders. Project team leaders can also recommend eliminating certain
process steps or deliverables without having to go through multiple layers of
approval. They simply include their recommended exceptions in their initial
project plans. The only caveat is for those deliverables ordinarily required in
the Design History File (DHF) which require formal written justification.
Beyond Compliance: Medical Device Product Development 6

7.
Additional Process Definition and
Work Flow Structure Best Practices
The study revealed a number of other proven practices to consider:
Meeting with the FDA early and often to receive feedback on regulatory
plans well before starting full-scale development. FDA representatives are
often glad to provide candid feedback and can save a company countless
hours pursuing the wrong path, but avoid presenting the FDA with open-
ended questions and approach them with a pre-conceived solution instead.
If there are flaws with a planned approach, the FDA will point them out,
leaving time to adjust. The alternative is to find out further downstream
when corrections will cost you significant amounts of time and money.
Where possible, moving validation activity upstream in the design cycle.
Leading companies recommend investing in rapid prototyping capabilities
and to start testing as soon as production equivalent test units can be
produced. Despite the risk that any subsequent design change would
trigger repeat testing and drive up development cost, negatively impacting
resource utilization, and in the end, delaying product introduction, these
companies concluded that this approach was worth pursuing, especially for
their Class I devices.
“If the design is 20 percent new and 80 percent design
re-use, we now test 20 percent, not 100 percent.”
Avoiding time spent testing complete product systems by testing only
those subsystem design elements that are new. One company that had
recently made time-to-market gains through a design re-use initiative was
also able to improve their test efficiency when they realized how much time
and money they were wasting by testing complete product systems when
only certain subsystem design elements had changed. By testing only those
subsystems that were new, this approach not only saved time and resources,
but also eased a significant test reporting burden. As one executive
described, “if the design is 20 percent new and 80 percent design re-use,
we now test 20 percent, not 100 percent.” This approach is facilitated
by utilizing a new modular platform architecture and with software
automation tools that simplify archival and retrieval of past test reports
Boosting efficiency and regulatory filing success rate by simply keeping
regulatory submission in mind at each stage of the design cycle. Early stage
reports are written with regulatory submission in mind and build toward
final submission. This concept is reinforced in all deliverable templates and
training materials.
7 Beyond Compliance: Medical Device Product Development

8.
Innovation Governance and Decision
Making: Knowing the Who, What,
When, and How – And Sticking to It
Kalypso research revealed that while all of the participating companies
utilize a formal phase gate process with an executive governance team in
place to make project go/no-go decisions, some have proven more effective
than others. Those companies more effective in meeting business objectives
utilize the following practices:
• Staff a complete multi-function governance team, including
representation from Quality and Regulatory Affairs
• Clarify the governance team’s role as business decision makers
• Establish a governance team leader who holds team members
accountable and actively drives the team to make the tough calls
• Take responsibility for ensuring proper resource allocation
across all projects
• Utilize pre-established gate objectives and decision making criteria
• Ensure that gate decisions are in alignment with portfolio objectives
• Make clear, unambiguous decisions that stick
• Leave the implementation-level decisions
to empowered project teams
• Keep product review meetings focused on the business
decision at hand without getting off into the weeds
The top performing companies are making improvements and achieving
clarity around the “who, what, when, and how” of the decision making
process. Key to meeting business objectives is ensuring this approach is
consistently applied.
Project Teams and Team Structure:
Establishing Roles to Achieve Both
Compliance and Project Success
While all participating companies have implemented some form of an
empowered cross-functional project team structure, few felt that their
project teams were consistently high performing. The most common
problems cited were missed schedules caused by changing product
requirements, unanticipated regulatory requirements, and ineffective
resource allocation.
Leading companies with high-performing project teams recognize that
implementation-level decisions are best left to accountable project teams
Beyond Compliance: Medical Device Product Development 8

9.
who are closest to the day-to-day work. They establish an appropriate team
structure, provide the right level of guidance, staff the teams for success,
and get out of the way.
All companies felt it was critical to staff core project teams with a
knowledgeable Regulatory Affairs representative. While most companies
include both Quality and Regulatory representatives on core project teams
from the get-go, Kalypso research found that the effectiveness of the role
varies greatly from company to company. On more successful project teams,
the Quality and Regulatory representatives not only advise team members
on how to stay design control compliant, but also play an active role in
helping the project team when making the delicate and all too common
tradeoffs needed to meet higher level business objectives.
A primary role for the Quality and Regulatory representative is to keep
implementation-level decisions consistent with corporate-wide quality
and regulatory strategies. Research showed that projects tend to get into
trouble when their Quality and Regulatory representatives take on a process
enforcer role and are viewed as “process policemen” who only speak up
when there is a process “violation,” pointing out problems instead of taking
an active role in guiding the team toward solutions. Companies would
like to see the role shift from compliance adherence to both compliance
and project success. This change is behavioral and requires a mindset
transformation that is best achieved when reinforced from the highest
levels in the organization. When this is successful, project teams willingly
consult their regulatory representative, who is viewed as someone who
knows how to interpret regulations and has the experience to figure out
what the FDA really wants.
The more effective Quality and Regulatory team members are able to
anticipate issues and help their project teams create a strategy early in
the project’s planning stages. Several companies indicated they assign a
dedicated Regulatory Representative while the project is still in the concept
phase and, in some cases, as early as idea approval. At that point in the
program, the Regulatory representative is tasked with formulating a robust
regulatory strategy. Even at this early stage enough information is known
about the product concept to allow the Regulatory team member to initiate
regulatory plans in parallel with market confirmation and project planning
tasks. Leading companies who have realized the benefits of early Regulatory
involvement in project planning are reaping the benefits through fewer
project re-directs, more accurate budgets, and improved schedule
predictability.
In formulating a regulatory strategy, the Regulatory team member looks
at the proposed product’s intended use, desired and “must-have” claims,
and known label requirements. Plans for clinical studies are formulated,
including study objectives, the number of studies, duration, timing, and
9 Beyond Compliance: Medical Device Product Development

10.
“Leading companies who have cost. FDA classification, international regulatory
requirements, predicate devices, approval
realized the benefits of early requirements, alternate submission approaches,
submission risks, contingency plans, and timing
Regulatory involvement in project are all determined. The Regulatory team member
planning are reaping the benefits also looks at the regulatory plan’s impact to
production, product cost, competitive positioning,
through fewer project re-directs, and the overall project schedule and budget.
more accurate budgets, and Many of the companies interviewed have also
added reimbursement strategy as a Regulatory
improved schedule predictability.” Affairs responsibility.
Software Systems and Tools:
Improving Development Effectiveness
and Easing Compliance Challenges
Through Automation
Kalypso research revealed that the top performing companies are
benefiting from the use of software solutions in design processes, quality
functions, and project management. When applied at the right time with
a well thought-out, strategic implementation plan, software tools can
help accelerate the path to development process maturity, improve team
collaboration, and remove much of the administrative burden associated
with regulatory compliance.
Design Process and Information Management
The majority of top performers have implemented a requirements
management software package. Requirements management packages can
make it easier to manage the complex landscape of product requirements,
which can often number in the hundreds. More and more, companies are
using tools like these to trace product requirements back to user needs
or even to the original voice-of-customer input, and forward to resulting
hardware or software specifications. This complex web of traceability
can quickly become an administrative nightmare when using desktop
applications such as Word or Excel. A robust requirements management
software package can greatly simplify document generation and more
importantly, make it easier to flag all requirements that must be revisited
when downstream requirements change. This functionality makes the
entire change history much more transparent, simplifying the audit process
and making FDA or internal audit requested change justifications and
approvals easy to find.
One company, whose requirements traceability administrator had been
using a requirements management software package for eight years,
couldn’t imagine life without it: “In terms of change history, we went from
Beyond Compliance: Medical Device Product Development 10

11.
trying to find a needle in a haystack to giving everyone on the program
clear visibility literally with the touch of a button.” Other added benefits
include simplified revision control and more efficient collaboration with co-
development partners.
”In terms of change history, we went from trying to find
a needle in a haystack to giving everyone on the program
clear visibility literally with the touch of a button.”
All participating companies use some form of electronic document control,
mostly focusing around Design History File management, ongoing Device
Master Record management, and FDA submission document management.
Leading companies utilize a system to provide a single “product data
record” or “source of truth” that is then integrated with other systems
for manufacturing and quality management. Leading companies are also
utilizing those document control systems that provide full text search
for advanced information access (AIA), document linking, and electronic
signature capabilities compliant with 21 CFR Part 11. Companies have
reported a cost savings of close to 70 percent based on reducing the amount
of time necessary for product development teams to search and utilize
existing documents, and in reducing the time necessary for gaining sign-off
on necessary design steps.
Additionally, the top companies do not utilize a paper back-up process
for document control, but adhere to strict and robust data archiving and
disaster recovery policies and procedures. The most effective companies
even utilize the document control system during audits by the FDA, as
opposed to printing documents for the regulators to review.
Quality Functions
Based on the FDA Quality System Regulation (QSR), all medical device
companies must have a corrective action / preventive action process (CAPA) in
place. The majority of medical device companies utilize some form of software
for managing the manufacturing issues, customer complaints, and Medical
Device Reports. Those utilizing enterprise class software tools have seen great
benefit including an 88% time improvement in Non-conforming Material
Reports (NCMR) closures, and a 60% time improvement in CAPA closures.
Surprisingly, with the high value of product quality information in guiding
product improvement and opportunities for new product sets, most
medical device companies do not have any form of electronic integration
between their quality management systems (home-grown or commercially
11 Beyond Compliance: Medical Device Product Development

12.
available off-the-shelf (COTS)) and their product development software
systems. Leading companies however have implemented enterprise-class
CAPA management systems and have successfully integrated them into their
product development systems.
Project Management
All research participants use some form of software for project
management, with the overwhelming majority utilizing stand-alone
Microsoft Project® as the schedule management tool. Many leading
medical device manufacturers have gone beyond MS Project® and are
utilizing enterprise-class project management tools, which not only
allow individual project managers and team members to update their
specific projects, but also provide visibility to management across multiple
projects in various locations. However, these companies have not simply
implemented technology; they have also systematically increased direct
accountability for all new product development resources, provided
communication training to support accountability (e.g., what does “done”
mean), and allowed an appropriate level of flexibility for empowered
project teams to determine what aspects, information, and even process
steps are involved in launching individual products or platforms.
Common Software Tool Challenges
A key point to consider in the use of any software solution for the purposes
described above is the concept of security and access control. Those
companies who used fewer systems but cordoned off access to specific areas,
fields of data, or applications based on the function of the individuals were
more likely to rate their new product development process as mature and
effective.
Additionally, an important but costly aspect to the implementation and use
of software solutions for new product development in the medical device
industry is the requirement for validation of these systems per the Quality
Systems Regulation. The QSR states that if “computers or automated data
processing systems are used as part of production or the quality system,
the [device] manufacturer shall validate computer software for its intended
use according to an established protocol” (see 21 CFR §820.70(i)). Research
indicates that medical device companies who implement enterprise software
technologies from vendors who provide a validation protocol for the base-
line implementation state of their software save approximately 50% of the
time and cost to validate those systems (e.g., Some systems come “out of the
box” with validated workflows for CAPA).
Finally, software systems users sometimes found the tools to be too complex
for their own good. In trying to capture the functionality needs of all
potential customers, the systems end up with many features that rarely
Beyond Compliance: Medical Device Product Development 12

13.
get used. Companies feel compelled to use the advanced features, change
their processes to integrate them, and end up frustrated when they find
they are not used often enough to be worthwhile. The old adage rings
true that automating poor processes just amplifies problems and that
broken processes should be fixed first. The companies interviewed also
underestimated the importance of executive-level and cross-functional “buy-
in”. Companies can avoid these issues by taking a more strategic approach to
system selection and implementation, starting first by gaining agreement on
the business imperatives.
Medical Device Companies Can Balance
Product Development Effectiveness
with Regulatory Compliance
Medical device companies are experiencing growing pains as they navigate
the challenging waters of regulatory compliance while simultaneously
keeping up with the pace of innovation. When it comes to implementing
product development processes that comply with regulations, many have
overcompensated, resulting in overly-bureaucratic systems that are impacting
delivery performance and causing them to come up short on time to market,
R&D ROI, new product revenue, and schedule predictability goals.
Companies are under pressure to re-evaluate current processes and
determine how best to implement a development approach that meets
design control requirements while ensuring a fast, effective flow of
successful new products. Though a single process design has the advantage
of one system for both business and quality system needs, this approach
increases opportunities for non-compliance and hinders project teams
that need flexibility to adapt business processes to specific project needs.
Separating business-oriented processes from rigidly-enforced design control
procedures enables project teams to use judgment and experience in
adapting process guidance to specific project needs without jeopardizing
design control compliance.
Other process definition and work flow practices that save time and avoid
development delays include meeting with the FDA early and often to receive
feedback before starting full-scale development, validating as soon as
production equivalent product test units can be produced and testing only
subsystem design elements that are new instead of complete product systems.
To meet product-driven business objectives, structuring governance and
decision making processes to achieve clarity around the “who, what, when
and how” is necessary. A formal phase gate process with an appropriately
staffed executive governance team can be leveraged by aligning gate
decisions with portfolio objectives, establishing clear leadership and leaving
implementation-level decisions to empowered project teams. Additionally,
13 Beyond Compliance: Medical Device Product Development

14.
project teams must be structured to dually achieve both compliance and
project success with a Regulatory Affairs representative who advises the
team on how to stay design control compliant and plays an active role in
helping to meet higher level business objectives. An effective Regulatory
Affairs representative keeps implementation-level decisions consistent with
corporate-wide quality and regulatory strategies, anticipates issues, and
plans appropriate contingencies during the early planning stages.
Lastly, the advantage of software tools can be significant when applied
at the right time with a well thought-out, strategic implementation plan.
Software tools can help accelerate the path to development process maturity,
improve team collaboration, and remove much of the administrative
burden associated with regulatory compliance. Business processes that can
be aided with software tools include requirements management, project
management, portfolio management, document management, and quality
management.
Implementing a program that couples product development effectiveness
with compliance is no easy task, but deploying a methodology that includes
improvements in process definition and work flow structure, innovation
governance and decision making, project teams and team structure, and
software systems and tools can help companies realize benefits including:
• Meeting and exceeding development effectiveness goals
• Achieving time to market goals
• Hitting planned product launch dates
• Eliminating unnecessary process bureaucracy
• Accelerating product development process maturity
These are benefits being realized today by companies that have achieved
an effective balance of product development processes maturity and
regulatory compliance. A mature, high performing product development
process with low compliance burden is the goal.
Top performing medical device companies are demonstrating how to
achieve this goal and have overcome industry challenges to deliver safe,
effective, and commercially successful medical devices.
Beyond Compliance: Medical Device Product Development 14

15.
About the Author
Noel Sobelman is a Partner with Kalypso, a leading innovation consulting firm serving
the medical device industry. Noel has over 18 years of consulting and industry
experience working with both small, fast-growth startups, and multi-division,
well-established corporations. He has held product line and business unit general
management positions with several leading technology-based companies, including
Motorola, Honeywell, and Kyocera, where he championed successful new product
and market growth initiatives.
Noel has a broad range of medical device company experience in the areas of
innovation management, portfolio planning and rationalization, product development,
and new product introduction. He has designed and implemented portfolio planning
systems, established technology and product strategy processes, facilitated voice-of-
customer and ideation workshops, implemented phase gate governance and decision-
making procedures, and led collaborative development and open innovation initiatives.
Noel has also led several high profile product development programs that have
received national recognition, including the USA Today/Rochester Institute
of Technology’s Quality Cup, PC Magazine’s Editors Choice, PR Magazine’s
“Best High Tech Consumer Launch”, and CNET’s “Best of CES” awards.
noel.sobelman@kalypso.com
Contributors: Marcus Yoder, Senior Manager marcus.yoder@kalypso.com
Jay Schierloh, Manager jay.schierloh@kalypso.com
Emily Adams, Consultant emily.adams@kalypso.com
About Kalypso
Kalypso is a consulting firm serving the world’s most innovative companies. The firm helps
clients to deliver on the promise of innovation. Service offerings encompass all aspects
of innovation including product strategy, development, introduction, commercialization,
lifecycle management, and PLM systems selection and implementation. In addition
to the firm’s deep industry, technology, operational, and training expertise, Kalypso
provides a flexible, collaborative approach to deliver unparalleled client satisfaction.
Products Ideas Innovation www.kalypso.com